AC-16(9)—Attribute Reassignment -- Regrading Mechanisms
>Control Description
Change security and privacy attributes associated with information only via regrading mechanisms validated using ⚙organization-defined techniques or procedures.
>Cross-Framework Mappings
>Supplemental Guidance
A regrading mechanism is a trusted process authorized to re-classify and re-label data in accordance with a defined policy exception. Validated regrading mechanisms are used by organizations to provide the requisite levels of assurance for attribute reassignment activities. The validation is facilitated by ensuring that regrading mechanisms are single purpose and of limited function.
Since security and privacy attribute changes can directly affect policy enforcement actions, implementing trustworthy regrading mechanisms is necessary to help ensure that such mechanisms perform in a consistent and correct mode of operation.
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What formal policies and procedures govern the implementation of AC-16(9) (Attribute Reassignment -- Regrading Mechanisms)?
- •Who are the designated roles responsible for implementing, maintaining, and monitoring AC-16(9)?
- •How frequently is the AC-16(9) policy reviewed and updated, and what triggers policy changes?
- •What training or awareness programs ensure personnel understand their responsibilities related to AC-16(9)?
Technical Implementation:
- •Describe the specific technical mechanisms or controls used to enforce AC-16(9) requirements.
- •What automated tools, systems, or technologies are deployed to implement AC-16(9)?
- •How is AC-16(9) integrated into your system architecture and overall security posture?
- •What configuration settings, parameters, or technical specifications enforce AC-16(9) requirements?
Evidence & Documentation:
- •What documentation demonstrates the complete implementation of AC-16(9)?
- •What audit logs, records, reports, or monitoring data validate AC-16(9) compliance?
- •Can you provide evidence of periodic reviews, assessments, or testing of AC-16(9) effectiveness?
- •What artifacts would you present during a FedRAMP assessment to demonstrate AC-16(9) compliance?
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